Security & Estate Group Asbestos Management Plan (AMP)

Security & Estate GroupAsbestos Management PlanCHAPTER 1 DEFENCE SPECIFICSECTION 1 THE ASBESTOS MANAGEMENT PLAN1.1 SEG is the area of Defence responsible for supporting the Australian Defence Force(ADF) and the whole Defence organisation in meeting their capability objectives bymanaging and sustaining the Defence estate of land, buildings and infrastructure. ThisAsbestos Management Plan (AMP) covers all bases, training areas, ranges and leased siteswhere plant, infrastructure, property and/or equipment is owned, stored, maintained oroperated by SEG.1.2 The management of any ACM that is part of a military platform rather than being part ofa building or infrastructure (i.e. any ACM contained in a military platform or spare parts for amilitary platform) is the responsibility of the controlling Group or Service and therefore is notcovered by this AMP. Units with military platform containing asbestos must create their ownasbestos management plan, in accordance with Regulation 429 of the WHS Regulations.1.3 The preparation for the disposal of Group or Service items containing ACM is also theresponsibility of the relevant Group or Service. SEG can facilitate the removal of asbestosfrom military equipment and inventory by providing technical assistance and aid throughassisting with the engagement of an appropriate person to conduct the asbestos removal worksand air monitoring. Arranging the disposal of these inventory items is undertaken through thebase services contract; however, the Unit or Group responsible for the inventory or equipmentis responsible for all remediation and disposal costs.SECTION 2 AIM1.4 The overarching aim of this AMP is to safeguard the people who occupy, maintainand/or visit the Defence estate against exposure to airborne asbestos fibres. This overarchingaim is to be achieved by implementing and maintaining the following eight (8) asbestosmanagement objectives:1.4.1Objective 1 - To eliminate all very high and high risk instances of ACM fromthe estate.1.4.2Objective 2 - To develop a safety and environmental incident response planapplicable to typical instances of asbestos found on the estate.1.4.3Objective 3 - To deliver an effective asbestos management strategy, includingremediation works programs.1.4.4Objective 4 - To adopt safe work practices and asbestos managementprocedures to ensure that no employee, contractor or visitor is exposed to potentialsources of airborne asbestos fibres.1.4.5Objective 5 – To ensure that the Risk Compliance & EnvironmentalManagement Module (known through this document as the asbestos module) is up-todate and accurate, through a robust survey inspection program and the timely entry ofasbestos data onto the asbestos module.Page 7 of 85Version: 5.1Doc Date: Mar 2022

Security & Estate GroupAsbestos Management Plan1.4.6Objective 6 - Ensure Defence meets all of its statutory WHS obligationsrelating to asbestos and asbestos management.1.4.7Objective 7 - To provide a consistent and effective approach to themanagement of ACM in buildings, plant, infrastructure and in soils across the Defenceestate.1.4.8Objective 8 - To develop effective lines of communication with stakeholders toensure that stakeholders are informed in a timely manner with accurate and relevantinformation.1.5 The long term aim for the Defence estate is to eliminate the asbestos risk from theDefence estate via programmed asbestos remediation works, in accordance with Regulation35 of the WHS Regulations. Where elimination is not possible in the short to medium term, inaccordance with WHS Regulations 36 and 37, the intent is to minimise the risk so far as isreasonably practicable (SFARP) by implementing and maintaining control measures inaccordance with the hierarchy of risk controls.SECTION 3 ROLES AND RESPONSIBILITIES1.6 Defence and Officers of Person Conducting a Business or Undertaking (PCBU) – Underthe Work Health and Safety Act 2011, Defence has designated the Secretary of theDepartment of Defence, the Chief of the Defence Force, the Associate Secretary, Vice Chiefof the Defence Force and all Group Heads and Service Chiefs, as Officers of the PCBU, andmust exercise due diligence to ensure that their workers comply with the Work Health andSafety Act 2011. All workers must support these Officers in performing their duty. Examplesof duties owed to workers and others in relation to asbestos management include:1.6.1Eliminating or minimizing, SFARP, the risk of exposure to airborne asbestosand ensuring the exposure standard for asbestos is not exceeded.1.6.2Providing suitable and specific information, training and instruction toworkers, including contractors and sub-contractors.1.6.3Programming assurance activities to verify all workers, contractors and subcontractors are complying with their legislative obligations.1.7 All Officers of a PCBU must exercise due diligence to ensure that WHS duties arebeing met. Officer duties pertaining to asbestos include gaining an understanding of thehazards and risks associated with asbestos as well as ensuring appropriate resources andprocesses are available and used to eliminate or minimise risks to health and safety associatedwith asbestos.1.8 Directorate of Work Health and Safety (DWHS) - As the authority for SEG asbestospolicy, DWHS will undertake reviews of this AMP in accordance with the requirements ofRegulation 430 of the WHS Regulations (i.e. whenever a triggering event set out underRegulation 430 takes place and, in all circumstances, at least every 5 years).Page 8 of 85Version: 5.1Doc Date: Mar 2022

Security & Estate GroupAsbestos Management Plan1.9 Regional Services – Defence regional and base services are managed under a zonestructure by three Assistant Secretary Regional Services. The Assistant Secretary RegionalServices are responsible for the oversight of asbestos management and remediation servicesdelivered within their zone. The Assistant Secretary Regional Services will ensure that SEG(Zone WHS) staff are appointed to support oversight.1.10 Base Manager (BM) - The BM has the authority and responsibility for common areaWHS management and to support the delivery of SEG products and services at the base level.Other support services outside of the BM responsibilities are to be agreed with the SADFOand HRU. These responsibilities include:1.10.1 Coordinating and maintaining cooperative consultation and workingrelationships with the SADFO and all HRU in regards to all asbestos related issues, withsupport of the Zone WHS Officer.1.10.2 Ensuring that the most current version of this AMP is widely disseminated toall base stakeholders through the Base Management Forum, the Base WHS Committeeand via promulgation on base websites.1.10.3 Ensuring employee, contractor, consultant and visitor concerns about asbestosare dealt with in a satisfactory and timely manner, with support of the Zone WHSOfficer.1.10.4 Raising and coordinating an asbestos “Hot Issues Brief” when required, withsupport of the Zone WHS Officer.1.10.5 Initiating Work Health & Safety Investigations as prescribed in SafetyMan –Work Health and Safety Event Investigation Policy Guidance - Levels of Investigation.1.11 Capital Facilities and Infrastructure (CFI) – CFI is responsible for ensuring that allprojects undertaken by their contractors are conducted in a manner that is cognisant ofasbestos hazards present on the Defence estate; that projects comply with WHS legislation,Australian Standards, the Handover/Takeover (HOTO) Process and this AMP when providingservices to Defence and that they (CFI) consult, cooperate and coordinate activities withDefence and any other person who holds a relevant WHS duty in the same matter. CFIresponsibilities include ensuring that:1.11.1 CFI-engaged contractors conduct any asbestos related projects to the standardrequired and that all instances of ACM being removed, disturbed, enclosed or sealed areupdated in GEMS.1.11.2 CFI-engaged contractors are appropriately qualified/licenced and aware of theirresponsibilities with regards to asbestos management requirements.1.11.3 This AMP and the Defence asbestos register is reviewed by all CFI-engagedcontractors prior to any work commencing on the Defence estate.1.11.4 With the exception of the ACT,7 the licenced asbestos removalist shall notifyComcare whenever undertaking asbestos removal works involving all friable asbestosand / or all non-friable asbestos 10m2.7The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantityPage 9 of 85Version: 5.1Doc Date: 14 Feb 2022

Security & Estate GroupAsbestos Management Plan1.11.5 All notifiable incidents are reported to Comcare by CFI using the SEGGuidance for the Reporting and Managing of Work Health and Safety Events.1.12 Groups and Services Conducting Works on the Estate – Other Groups and Servicesincluding, but not limited to CIOG, CASG and DSTG may undertake projects or works on theEstate outside of SEG project management arrangements. The Group or Servicecommissioning such work is responsible for ensuring that all projects undertaken by theircontractors are conducted in a manner that is cognisant of asbestos hazards present on theDefence estate, that they comply with WHS legislation, Australian Standards, theHandover/Takeover (HOTO) Process and this AMP when providing services to Defence andthat they consult, cooperate and coordinate activities with Defence and any other person whoholds a relevant WHS duty. This includes ensuring that:1.12.1 This AMP and the asbestos register is reviewed prior to the commencement ofany work. All contractors are cognisant of the risk that unidentified ACM may bepresent in inaccessible areas, underground services and in soils. Safe work proceduresmust include planning for immediate response to contain any unexpected discovery ordisturbance until incident management procedures are initiated.1.12.2 Where asbestos is disturbed or damaged as a direct result of the work, theGroup or Service is responsible for funding the remediation of the immediate affectedarea to the standard required. Incident management and remediation can be initiated bycontacting the BSSC to engage SEG’s EMOS Contractor on a ‘user pays’ basis.Alternatively, the Group or Service conducting the work may engage an asbestosremoval contractor to conduct the remediation in accordance with the requirements ofthis AMP.1.12.3 When the Group or Service elects to directly engage an asbestos removalcontractor, the contractor must be appropriately qualified/licenced and aware of theirresponsibilities with regards to asbestos management requirements. This AMP isreviewed by all contractors prior to any remediation work on the Defence estate. Alldocumentation pertaining to any instances of ACM being removed, disturbed, enclosedor sealed shall be submitted to the EMOS for updating of the Asbestos Register.1.12.4 The licenced asbestos removalist notifies Comcare whenever undertakingasbestos removal works involving friable asbestos and / or non-friable asbestos 10m2.81.13 All notifiable incidents arising as a result of the work are reported to Comcare by theGroup or Service who conducting the work.1.14 In this AMP the following definitions of contractor apply:1.14.1 Contractor - the term contractor applies to ALL contractors and sub-contractorsoperating on the Defence estate, including the EMOS Contractor and any subcontractors of the EMOS Contractor.1.14.2 EMOS Contractor - this term refers specifically to the contractor contracted toprovide the Estate Maintenance and Operations Services to the Department of Defence(including any sub-contractors of the EMOS Contractor).8The Australian Capital Territory requires notification for all asbestos works, regardless of type or quantityPage 10 of 85Version: 5.1Doc Date: 14 Feb 2022

Security & Estate GroupAsbestos Management Plan1.14.3 Non-EMOS Contractor - this term refers to all contractors or sub-contractors,except the EMOS Contractor or any sub-contractors of the EMOS Contractor.1.15 Other Contractors – SEG manages a broad range of contracts and consultants(contractors) to deliver both minor and major capital works; the estate works program,remediation works, maintenance, waste disposal and other services on Defence bases.1.16 Principal Contractors must ensure that all of their sub-contractors are cognisant ofasbestos hazards present on the Defence estate, that they comply with WHS legislation whenproviding services to Defence and that they must consult, cooperate and coordinate activitieswith Defence and any other person who holds a WHS duty in the same matter. SEG- engagedContractors are responsible for:1.16.1 Ensuring that their workers and sub-contractors are appropriatelyqualified/licenced and aware of their responsibilities with regards to asbestosmanagement requirements.1.16.2 Ensuring their workers and sub-contractors are provided with asbestosawareness training.1.16.3 Ensuring that this AMP and the Defence asbestos register is reviewed by allcontractors and sub-contractors prior to any work commencing on the Defence estate.1.16.4 Complying with relevant Commonwealth/State/Territory legislation andDefence procedures, including the Handover/Takeover (HOTO) Process and this AMP.1.16.5 Ensuring the licenced asbestos removalist notifies Comcare and theState/Territory regulatory authorities when required.1.16.6 Reporting asbestos related notifiable incidents to Comcare, State/TerritoryRegulators and Defence.1.17 Directorate of Estate and Land Management (DELM) – As the Product Director(PD) for Estate Upkeep, DELM is responsible for ensuring that the EMOS Contractor (andtheir sub- contractors) are undertaking all base service contract activities in a manner that iscognisant of asbestos hazards present on the Defence estate and that they comply with WHSlegislation, Australian Standards, the Handover/Takeover (HOTO) Process and this AMP.This includes:1.17.1 Undertaking assurance activities on contractor services supplied under the baseservices contract (such as ensuring that contractors are supplying all relevant asbestosworks specified under the base services contract).1.17.2Ensuring that the supplied works are to the standard required.1.17.3 Ensuring that GEMS is maintained (including quality assurance of the datadelivered under the asbestos inspections program).1.18 DELM is also responsible for ensuring that any EMOS Contractor related noncompliance is rectified or escalated to the Contract Authority for rectification.Page 11 of 85Version: 5.1Doc Date: 14 Feb 2022

Security & Estate GroupAsbestos Management Plan1.19 EMOS Contractor - The EMOS Contractor is to undertake its contractual obligations9in-line with legislation and the processes set out in relevant Defence policy, including thisAMP.1.20 Directorate of Estate Works Program Office (DEWPO) - As the PD for the EstateWorks Program, DEWPO is responsible for ensuring that all projects undertaken by theProject Delivery Services (PDS) contractors through the Estate Works Program (EWP) areconducted in a manner that is cognisant of asbestos hazards present on the Defence estate andthat contractors comply with WHS legislation, Australian Standards, the Handover/Takeover(HOTO) Process and this AMP. This includes:1.20.1 Ensuring that PDS contractors (and sub-contractors) conduct any asbestosrelated project works to the standard required.1.20.2 That all instances of ACM being removed, disturbed, enclosed or sealed areupdated in GEMS.1.20.3 Ensuring all notifiable incidents are reported to Comcare by DEWPO using theSEG Guidance for the Reporting and Managing of Work Health and Safety Events.1.21 DEWPO is also responsible for ensuring that any EWP related asbestos non-complianceis rectified or escalated to the Contract Authority for rectification.1.22 Head of Resi

Directorate of Estate Works Program Office . DEQMS . Defence Estate Quality Management System . DPN . Defence Protected Network . DWHS . Directorate of Work Health and Safety . EA . Estate Appraisal . . DEMS and IBIS. Security & Estate Group Asbestos Management Plan Page 6 of 85 Version: 5.1 Doc Date: Mar 2022 . GEMS Garrison Estate .